The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more

The French 3 Percent Distribution Tax: Claiming a Refund -
Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

The number of additional months of funding for transportation projects under a $8 billion bill introduced late last night in the House. Notably — as anyone on Sesame Street could tell you — the number 5 is not the same as the...more

The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more

On Wednesday, 8 July 2015, George Osborne delivered the UK Summer Budget. The first Budget of the new Conservative government (and the second Budget of 2015), the Summer Budget is wide-ranging in scope and potentially...more

The new tax announcements are designed to improve productivity and correct imbalances in the tax system.
On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more

Following the taxpayer’s victory in the recent Supreme Court decision of HMRC v Anson, UK resident members of Delaware LLCs may now be entitled to claim relief against their UK tax liabilities for US tax paid on their share...more

Delaware LLC held to be UK tax transparent -
The UK Supreme Court has handed down its judgment on the final appeal in the Anson case, in which it treated a taxpayer's interest in a Delaware LLC as transparent for UK tax...more

The UK Supreme Court delivered an unexpected final judgment on 1 July 2015 in the long-running case of Anson v Commissioners for Her Majesty’s Revenue & Customs [2015] UKSC 44. Reversing the decisions of the Upper Tribunal...more

1. Executive Summary -
The U.K. corporate tax landscape has been undergoing reform for a number of years. A significant part of the changes involves the ongoing modernization of the U.K.’s complex tax regime for...more

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of...more

Chinese companies are growing in the UK at an unprecedented rate, adding a significant contribution to the UK economy through growth and employment.
Research by the China Daily into UK businesses with Chinese parent...more

In a move designed to breathe life into the United Kingdom’s North Sea oil and gas industry, the United Kingdom’s Chancellor of the Exchequer has announced a suite of tax cuts as part of the 2015 Budget. The cuts are a...more

Tax relief changes announced for film and television and a new coproduction treaty.
The UK Government published the Finance Bill 2015 on 24 March 2015. We set out below the bill’s key impacts on the UK film and...more

Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation....more

Before the Budget was announced, there was natural apprehension that, given the impending general election, the Chancellor would pander to the electorate and sail off course from this Government’s carefully navigated path...more

The Chancellor of the Exchequer’s final Budget of the current Parliament, given on 18 March 2015, was held in the shadow of the UK’s general election on 7 May 2015. With the backdrop of the UK’s GDP growth increasing,...more

BACKGROUND AND INTRODUCTION -
The UK Government has announced the introduction of the Diverted Profits Tax (or 'DPT') - a new tax which will have effect from 1 April 2015. The tax is intended to target two types of...more

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES -
During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google's chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK,...more

A New Tax on doing business in or through the UK -
The UK is on course to enact a new tax (the "DPT") with extraterritorial scope which will apply to profits arising on or after 1 April 2015 and will be applied at a...more

The UK Treasury has published the draft legislation for the new Diverted Profits Tax (DPT), which it plans to introduce from 1 April 2015. This has been unofficially described as the “Google Tax”, and represents part of the...more

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS -
The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015.
The government has published...more

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